Associated enterprises transfer pricing adjustment allows reallocation of profits and mandates reciprocal tax correction. Article 9 permits inclusion in taxable profits where associated enterprises-by reason of direct or indirect participation in management, control or capital, or common participation-enter into commercial or financial conditions differing from those between independent enterprises, and mandates that where one Contracting State taxes such reallocated profits and the other State also taxes them, the latter shall make an appropriate adjustment after consultation and with regard to the Agreement's provisions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Associated enterprises transfer pricing adjustment allows reallocation of profits and mandates reciprocal tax correction.
Article 9 permits inclusion in taxable profits where associated enterprises-by reason of direct or indirect participation in management, control or capital, or common participation-enter into commercial or financial conditions differing from those between independent enterprises, and mandates that where one Contracting State taxes such reallocated profits and the other State also taxes them, the latter shall make an appropriate adjustment after consultation and with regard to the Agreement's provisions.
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